CMMC is no longer a future idea.
The Department of War is already putting it into contracts.
Many DoW contractors are still asking the same question.
How will the DoW actually implement CMMC, and when will it affect my contracts?
Many contractors assume CMMC will be applied across all contracts at once. That is not how the DoW is handling it.
Instead, CMMC is being rolled out in phases. Some solicitations will include CMMC requirements early, while others will not. This makes planning difficult, especially for companies that are unsure when compliance becomes required to win work.
Contractors that wait for a clear signal often find out too late.
How the DoW Will Implement CMMC in Contracts
The DoW is implementing CMMC through updates to DFARS clauses and contract language.
CMMC requirements will appear directly in solicitations and contracts. Each contract will state the required CMMC level based on the type of information involved, such as Federal Contract Information or Controlled Unclassified Information.
During the rollout, program offices decide when to include CMMC. Over time, CMMC will become standard for contracts involving sensitive data. When CMMC is required, it becomes a pass or fail condition for award.
What Contractors Must Do Before Award
When a contract includes CMMC, contractors must already meet the required level.
For CMMC Level 1 and Level 2 self-assessment contracts, contractors must complete the assessment and submit accurate results in SPRS. For CMMC Level 2 certified contracts, a C3PAO is required before award.
There is no grace period after award. If compliance is not in place, the contractor is not eligible to move forward.
Consequences of Not Being Ready
Contractors that are not ready may lose bids without clear feedback.
Proposals can be removed from competition. Awards can be delayed or canceled. Subcontractors may be replaced if they cannot meet flow-down requirements.
Inaccurate compliance claims also increase audit and enforcement risk. As enforcement tightens, the cost of being unprepared continues to rise.
While this may sound challenging, CMMC implementation follows a predictable pattern.
Once contractors understand how CMMC is applied in contracts, preparation becomes more manageable.
Contractors that prepare early gain a clear advantage.
They can respond quickly when CMMC appears in a solicitation. They avoid emergency remediation and reduce the risk of lost eligibility. Early readiness also builds confidence with primes and contracting officers.
As CMMC becomes more common across the DoW, prepared contractors will be positioned to compete without disruption.
If you want to be ready before CMMC appears in your contracts, start with readiness.
Download the CMMC Level 2 Audit Checklist to see what auditors look for, what evidence is required, and where contractors most often fall short. This checklist helps you prepare before compliance becomes a condition for award.
FAQ: CMMC Implementation and Contract Readiness
When will CMMC be required in DoW contracts?
CMMC requirements will be added to DoW contracts over time, not all at once. Program offices decide when to include CMMC in solicitations, and when it appears, compliance becomes required before award.
Can I win a DoW contract and become CMMC compliant later?
No. If a contract includes CMMC requirements, contractors must already meet the required level before award. There is no grace period after winning the contract.
How will the DoW verify CMMC compliance?
The DoW verifies compliance through self-assessments submitted in SPRS or through third-party CMMC certifications, depending on the contract. Contracting officers use this information to confirm eligibility.
Does CMMC apply to subcontractors?
Yes. CMMC requirements flow down to subcontractors handling Federal Contract Information or Controlled Unclassified Information. Primes may remove or replace subcontractors that cannot meet required CMMC levels.
What happens if my compliance claims are inaccurate?
Inaccurate claims can lead to audits, contract loss, or enforcement action. As oversight increases, contractors are expected to support all cybersecurity claims with documentation and evidence.
What should contractors do now to prepare?
Contractors should identify which CMMC level applies to their work, assess current gaps, and begin documentation and remediation early. Preparation before CMMC appears in a solicitation reduces risk and cost.
